AGRI GOLD FOODS AND FARM PRODUCTS LIMITED,VIJAYAWADA vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-2(1), VIJAYAWADA

Bench: Us:

disallowances restricted the assessee’s returned loss to an amount of (-) Rs. 1,07,24,316/-. 6 Agri Gold Foods and Farm Products Limited 7. Subsequently, the A.O. initiated the reassessment

VENUGOPAL NIMMAGADDA,VIJAYAWADA vs. INCOME TAX OFFICER, WARD-3(3), VIJAYAWADA

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.212/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2012-13) Venugopal Nimmagadda Vs. Income Tax Officer D.No.21-10-29, Flat No.101 Ward-3(3) Anu Heights, 2Nd Lane Vijayawada Srinagar Colony Satyanarayanapuram Vijayawada [Pan : Adapn2791A] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

reassessment proceedings u/s 147 of the Act on the observation that the assessee took loan from Andhra Bank, Gudiwada Branch for excavation of fish tanks and pisiculture etc. which is not utilised for the business purpose for which it was taken and disallowed

GUNTUPALLI NAGESWARA RAO,IBRAHIMPATNAM vs. INCOME TAX OFFICER, WARD 1(1), VIJAYAWADA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

disallowance of deductions under Chapter VIA of Rs.3,84,267/- made vide assessment order passed u/s.147 which is based on time barred notice u/s.148A(b), time barred notice u/s. 148 and invalid order passed u/s.148A(d) as per provisions of section 149(1)(b), since, the reassessment

GUNTUPALLI NAGESWARA RAO,IBRAHIMPATNAM vs. INCOME TAX OFFICER, WARD 1(1), VIJAYAWADA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

disallowance of deductions under Chapter VIA of Rs.3,84,267/- made vide assessment order passed u/s.147 which is based on time barred notice u/s.148A(b), time barred notice u/s. 148 and invalid order passed u/s.148A(d) as per provisions of section 149(1)(b), since, the reassessment

VISWAMANAVA SAMAIKYATA SAMSAT,GUNTUR vs. INCOME TAX OFFICER(EXEMPTIONS), GUNTUR

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No. 278/Viz/2023 (निर्धारणवर्ा/ Assessment Year :2014-15) M/S. Viswamanava Samikyata Vs. Income Tax Officer Samsat, Guntur. (Exemptions), Pan: Aaatv 1597 P Guntur. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessee By : Sri Gvn Hari, Advocate प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr सुिवधईकीतधरीख/ Date Of Hearing : 02/04/2024 घोर्णधकीतधरीख/Date Of : 28/05/2024 Pronouncement O R D E R

reassessment proceedings as void ab initio. 4. Without prejudice to Ground No.2, the Ld. CIT(A) is not justified in upholding the addition of Rs. 4,20,54,192/- made by the AO by disallowing

GMEDAPADU PACS,EAST GODAVARI vs. ITO, WARD-1, KAKINADA

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.573/Viz/2025 (निर्धारण वर्ा/Assessment Year:2018-19) Gmedapadu Pacs, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. Pan: Aaaag8455A (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri Kss Sarma, Ca रधजस् व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of Hearing: 16/10/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Society Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 18/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 10/02/2021 For Ay 2018-19. The Assessee Society Has Assailed The Impugned Order Passed By The Ao On The Following Grounds Of Appeal:

disallowance and without affording an opportunity to the assessee to file objections. The appellant argued that such action violates the principles of natural justice and the binding precedent of the Apex Court. I have carefully considered this ground and the applicability of the cited Supreme Court decision. The ruling in GKN Driveshafts (India) Ltd. pertains specifically to reassessment

ARRDY ENGINEERING INNOVATINS (P) LTD,ROURKELA vs. THE ACIT, CIRCLE - 3(1), VISAKHAPATNAM., VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

disallowance has resulted in additional tax liability and interest thereon. 2. The Ld. CIT(A) erred in confirming the order of the Ld. AO which was challenged by appellant on the ground that intimation of reassessment

ARRDY ENGINNERING INNOVATIONS (P) LTD,ROURKELA vs. THE ACIT, CIRCLE - 3(1), VISAKHAPATNAM., VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

disallowance has resulted in additional tax liability and interest thereon. 2. The Ld. CIT(A) erred in confirming the order of the Ld. AO which was challenged by appellant on the ground that intimation of reassessment

GVA INDUSTRIES PRIVATE LIMITED,CHHATTISGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

reassessment proceedings under section 147, alleging that the assessee had availed accommodation entries for purchases from certain suppliers. The AO added the entire purchase amount and transportation charges as bogus. The CIT(A) restricted the disallowance

KAPIL INFRA AVENUES PRIVATE LIMITED,VIJAYAWADA vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-1(1), VIJAYAWADA

In the result, appeal filed by the assessee is allowed for statistical purposes as indicated hereinabove

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.258/Viz/2023 (निर्धारणवर्ा/ Assessment Year : 2017-18) Kapil Infra Avenues Private Vs. Deputy Commissioner Of Limited, Income Tax, Vijayawada. Circle-1(1), Pan: Aadck 4944 P Vijayawada. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थीकीओरसे/ Assessee By : Sri Gvn Hari, Ar प्रत्यधर्थीकीओरसे/ Revenue By : Dr. Aparna Villuri, Sr. Ar सुिवधईकीतधरीख/ Date Of Hearing : 21/03/2024 घोर्णधकीतधरीख/Date Of : 26/03/2024 Pronouncement O R D E R Per S. Balakrishnan:

reassessment proceedings, it was observed by the Ld. 3 AO that the assessee has paid interest on sale advances ranged from 10% to 14% and average interest rate of 12% was applied to arrive at pro rata finance cost disallowance

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), VISAKHAPATNAM vs. SSNR PROJECTS PVT LTD, VISAKHAPATNAM

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.161/Viz/2022 ("नधा"रणवष"/ Assessment Year : 2019-20) Asst. Commissioner Of Income Vs. M/S. Ssnr Projects Private Tax, Circle-3(1), Limited, Visakhapatnam. Visakhapatnam. Pan: Aarcs 2464 C (अपीलाथ"/ Appellant) (""यथ"/ Respondent) C.O. No. 29/Viz/2023 (In आयकरअपीलसं./ I.T.A. No.161/Viz/2022) ("नधा"रणवष"/ Assessment Year : 2019-20) M/S. Ssnr Projects Private Vs. Asst. Commissioner Of Limited, Income Tax, Circle-3(1), Visakhapatnam. Visakhapatnam. Pan: Aarcs 2464 C (Cross Objector / Respondent In (Appellant In Appeal) Appeal) अपीलाथ"क"ओरसे/ Assessee By : Sri Samuel Nagadesi ""याथ"क"ओरसे/ Revenue By : Dr. Aparna Villuri, Sr. Ar सुनवाईक"तार"ख/ Date Of Hearing : 05/02/2024 घोषणाक"तार"ख/Date Of : 28/02/2024 Pronouncement O R D E R

reassessment by takinginto 7 consideration of the FTC filed by the petitioner on 02.02.2021.The respondent is directed to give due credit to the Kenya incomeof the petitioner and pass the final assessment order. Further, it ismade clear that the impugned order is set aside only to the extentof disallowing

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), VISAKHAPATNAM vs. SSNR PROJECTS PRIVATE LIMITED, VISAKHAPATNAM

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S Balakrishnanआयकरअपीलसं./ I.T.A. No.461/Viz/2024 (िनधा"रणवष"/ Assessment Year : 2020-21) Deputy Commissioner Of Income Vs. M/S. Ssnr Projects Private Tax, Circle-3(1), Limited, Visakhapatnam. Visakhapatnam. Pan: Aarcs 2464 C (अपीलाथ"/ Appellant) (""थ"/ Respondent) अपीलाथ"कीओरसे/ Assessee By : Sri Samuel Nagadesi ""ाथ"कीओरसे/ Revenue By : Dr. Aparna Villuri, Sr. Ar सुनवाईकीतारीख/ Date Of Hearing : 17/12/2024 घोषणाकीतारीख/Date Of : 31/01/2025 Pronouncement O R D E R

reassessment by taking into consideration of the FTC filed by the petitioner on 02.02.2021.The respondent is directed to give due credit to the Kenya income of the petitioner and pass the final assessment order. Further, it ismade clear that the impugned order is set aside only to the extent of disallowing

NO 368 KOLAKALURU PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LIMITED,GUNTUR vs. INCOME TAX OFFICER, WARD-1, TENALI

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.455/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) No. 368 Kolakaluru Vs. The Income Tax Officer, Primary Agricultural Co- Ward-1, Operative Credit Society Tenali. Limited, Tenali. Pan: Aaban6994Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/10/2025 घोषणा की तारीख/Date Of 10/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee-Society Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 25/06/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144 R.W.S 144B Of The 2 No. 368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited Vs. Ito

disallowance of deduction U/s. 80P of the Act. 4. Any other ground that may be urged at the time of appeal hearing.” 3. Also, the assessee-society has raised the following additional grounds of appeal: “1. The notice U/s. 148A(b) issued on 21/03/2022 did not provide for clear 7 days of time to the appellant and hence the same

JAI BHEEM SCHEDULED CASTE DRIVERS LABOUR CONTRACT COOPERATIVE SOCIETY LIMITED,RAJAHMUNDRY vs. THE INCOME TAX OFFICER, WARD-3, , RAJAHMUNDRY

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.696/Viz/2019 (ननधधारण वर्ा / Assessment Year : 2008-09) M/S Jai Bheem Scheduled Caste Vs. Income Tax Officer Drivers Labour Contract Cooperative Ward-3 Society Ltd. Rajahmundry D.No.72-3-1, Spinning Mills Road Lalacheruvu, Rajahmundry [Pan : Aaaa]7815K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

disallowance of exemption u/s 80P(2)(a)(vi) of the Act. 4. Any other grounds may be urged at the time of hearing. 5. The assessee filed petition for admission of following additional grounds and pleaded to admit the additional grounds and pass appropriate orders in the interest of rendering substantial justice. a. “On the facts and circumstances

MOTHER THERESSA EDUCATIONAL SOCIETY,AMALAPURAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTION CIRCLE, VIJAYAWADA

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

disallowance made on account of depreciation. He further submitted that there is no leakage of revenue and no tax is payable or no Page No. 5 I.T.A. Nos. 163&229/VIZ/2024 C.O. No. 01/VIZ/2024 Mother Theressa Educational Society income has escaped tax. The Ld.AR referring to Sub-Section (2) of section 270A where in it is clearly mentioned that a person

ACIT, EXEMPTION CIRCLE,, VIJAYAWADA vs. MOTHER THERESSA EDUCATIONAL SOCIETY, CHAITANYANAGAR

In the result, appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

disallowance made on account of depreciation. He further submitted that there is no leakage of revenue and no tax is payable or no Page No. 5 I.T.A. Nos. 163&229/VIZ/2024 C.O. No. 01/VIZ/2024 Mother Theressa Educational Society income has escaped tax. The Ld.AR referring to Sub-Section (2) of section 270A where in it is clearly mentioned that a person

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

disallowed depreciation amounting to Rs.12,20,05,735/- on the bogus plant and machinery claimed by the assessee. Further, the Ld. AO has also made addition on account of loss on sale of fixed assets for Rs. 2,50,000/-. On being aggrieved by the above additions, the assessee preferred an appeal before

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

disallowed depreciation amounting to Rs.12,20,05,735/- on the bogus plant and machinery claimed by the assessee. Further, the Ld. AO has also made addition on account of loss on sale of fixed assets for Rs. 2,50,000/-. On being aggrieved by the above additions, the assessee preferred an appeal before